ML072480037

Request for Additional Information Related to License Amendment Request Associated with Condensate Storage Tank Level (Tac No. MD6176)

ML072480037
Person / Time
Site:	Columbia
Issue date:	09/13/2007
From:	Lyon C F NRC/NRR/ADRO/DORL/LPLIV
To:	Parrish J V Energy Northwest
Lyon, C F, NRR/DLPM, 415-2296
References
TAC MD6176
Download: ML072480037 (6)

Text

September 13, 2007Mr. J. V. Parrish Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023)

Richland, WA 99352-0968

SUBJECT:

COLUMBIA GENERATING STATION - REQUEST FOR ADDITIONALINFORMATION RELATED TO LICENSE AMENDMENT REQUEST ASSOCIATED WITH CONDENSATE STORAGE TANK LEVEL (TAC NO. MD6176)

Dear Mr. Parrish:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated August 8, 2007, EnergyNorthwest submitted a license amendment request for Columbia Generating Station to revise the requirements of Technical Specification (TS) 3.3.5.2, "Reactor Core Isolation Cooling (RCIC) System Instrumentation," and TS 3.5.2, "ECCS [Emergency Core Cooling System]-Shutdown," to increase the Condensate Storage Tank (CST) level. The NRC staff is reviewing your submittal and has determined that additional information isrequired to complete its review. The specific information requested is addressed in the enclosure to this letter. During a discussion with Mr. G. Cullen of your staff on August 31, 2007, it was agreed that you would provide a response by November 30, 2007, to this request for additional information. The NRC staff considers that timely responses to requests for additional information helpensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-2296.Sincerely,/RA/Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-397

Enclosure:

Request for Additional Information cc w/encl: See next page June 2007Columbia Generating Station cc:Chairman Energy Facility Site Evaluation Council P.O. Box 43172 Olympia, WA 98504-3172Mr. Douglas W. Coleman (Mail Drop PE20)Manager, Regulatory Programs Energy Northwest P.O. Box 968 Richland, WA 99352-0968ChairmanBenton County Board of Commissioners P.O. Box 190 Prosser, WA 99350-0190Mr. William A. Horin, Esq.Winston & Strawn 1700 K Street, N.W.

Washington, DC 20006-3817Mr. Matt SteuerwaltExecutive Policy Division Office of the Governor P.O. Box 43113 Olympia, WA 98504-3113Ms. Lynn AlbinWashington State Department of Health P.O. Box 7827 Olympia, WA 98504-7827Technical Services Branch ChiefFEMA Region X 130 - 228th Street, SW Bothell, WA 98021-9796Mr. Mike HammondDepartment of Homeland Security FEMA/REP 130 - 228 th Street SWBothell, WA 98021-9796Regional Administrator, Region IVU.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005Senior Resident InspectorU.S. Nuclear Regulatory Commission P.O. Box 69 Richland, WA 99352-0069 Assistant DirectorNuclear Safety and Energy Siting Division Oregon Department of Energy 625 Marion Street NE Salem, OR 97301-3742Special Hazards Program ManagerWashington Emergency Management Div.

127 W. Clark Street Pasco, WA 99301 September 13, 2007Mr. J. V. Parrish Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023)

Richland, WA 99352-0968

SUBJECT:

COLUMBIA GENERATING STATION - REQUEST FOR ADDITIONALINFORMATION RELATED TO LICENSE AMENDMENT REQUEST ASSOCIATED WITH CONDENSATE STORAGE TANK LEVEL (TAC NO. MD6176)

Dear Mr. Parrish:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated August 8, 2007, EnergyNorthwest submitted a license amendment request for Columbia Generating Station to revise the requirements of Technical Specification (TS) 3.3.5.2, "Reactor Core Isolation Cooling (RCIC) System Instrumentation," and TS 3.5.2, "ECCS [Emergency Core Cooling System]-Shutdown," to increase the Condensate Storage Tank (CST) level. The NRC staff is reviewing your submittal and has determined that additional information isrequired to complete its review. The specific information requested is addressed in the enclosure to this letter. During a discussion with Mr. G. Cullen of your staff on August 31, 2007, it was agreed that you would provide a response by November 30, 2007, to this request for additional information. The NRC staff considers that timely responses to requests for additional information helpensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-2296.Sincerely,/RA/Carl F. Lyon, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-397

Enclosure:

Request for Additional Information cc w/encl: See next pageDISTRIBUTION

PUBLIC LPL4 R/F RidsAcrsAcnwMailCenter RidsNrrDeEicbRidsNrrDorlLpl4RidsNrrLAJBurkhardt RidsNrrPMFLyon RidsNrrDorlDprRidsOgcRpRidsRgn4MailCenter SMazumdar, NRRADAMS Accession Number: ML072480037*Memo datedOFFICELPL4/PMLPL4/LAEICB/BCLPL4/BCNAMEFLyonJBurkhardtWKemper*THiltz, MTM for DATE9/12/079/10/078/30/079/13/07OFFICIAL RECORD COPY REQUEST FOR ADDITIONAL INFORMATIONRELATED TO LICENSE AMENDMENT REQUEST ASSOCIATED WITHCONDENSATE STORAGE TANK LEVELENERGY NORTHWESTCOLUMBIA GENERATING STATIONDOCKET NUMBER 50-397The license amendment request (LAR), dated August 8, 2007, proposes the following TechnicalSpecifications (TS) changes:

!Condensate Storage Tank Level-Low Allowable Value in TS Table 3.3.5.2-1, Core Cooling Isolation System Instrumentation from "> 446 ft 0 inches elevation"to "> 447 ft 7 inches elevation."

!Condensate Storage Tank (CST) water level in SR [Surveillance Requirement]3.3.5.2-2, from "> 14.8 ft in a single CST or > 9.1 ft in each CST" to "> 16.5 ft ina single CST or > 10.5 ft in each CST."To support U.S. Nuclear Regulatory Commission (NRC) assessment of the acceptability of theLAR with regard to setpoint changes, please provide the following for each setpoint to be added or modified:1.Setpoint Calculation Methodology: Provide documentation (including samplecalculations) of the methodology used for establishing the limiting setpoint (or NSP) and the limiting acceptable values for the As-Found and As-Left setpoints as measured in periodic surveillance testing as described below. Indicate the related Analytical Limits and other limiting design values (and the sources of these values) for each setpoint.2.Safety Limit (SL)-related Determination: Provide a statement as to whether ornot the setpoint is a limiting safety system setting (LSSS) for a variable on which a safety limit (SL) has been placed as discussed in paragraph 50.36(c)(1)(ii)(A) of Title 10 of the Code of Federal Regulations (10 CFR). Such setpoints aredescribed as "SL-Related" in the discussions that follow. In accordance with 10 CFR 50.36(c)(1)(ii)(A), the following guidance is provided for identifying a list of functions to be included in the subset of LSSSs specified for variables on which SLs have been placed as defined in Standard Technical Specifications (STS) Sections 2.1.1, Reactor Core SLs, and 2.1.2, Reactor Coolant System Pressure SLs. This subset includes automatic protective devices in TSs for specified variables on which SLs have been placed that: (1) initiate a reactor trip; or (2) actuate safety systems. As such, these variables provide protection against violating reactor core safety limits, or reactor coolant system pressure boundary safety limits. Examples of instrument functions that might have LSSSs included in this subsetin accordance with the plant-specific licensing basis, are pressurizer pressure reactor trip (pressurized-water reactors), rod block monitor withdrawal blocks (boiling-water reactors), feedwater and main turbine high-water level trip (boiling-water reactors), and end-of-cycle recirculation pump trip (boiling-water reactors).

For each setpoint, or related group of setpoints, that you determined not to be SL-Related, explain the basis for this determination.3.For Setpoints That Are Determined to Be SL-related: The NRC letter to the NEISMTF dated September 7, 2005 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML052500004), describes Setpoint-Related TS (SRTS) that are acceptable to the NRC for instrument settings associated with SL-related setpoints. Specifically, Part "A" of the Enclosure to the letter provides limiting conditions for operations notes to be added to the TS, and Part "B" includes a checklist of the information to be provided in the TS Bases related to the proposed TS changes.a.Describe whether and how you plan to implement the SRTS suggested inthe September 7 letter. If you do not plan to adopt the suggested SRTS, then explain how you will ensure compliance with 10 CFR 50.36 by addressing items 3b and 3c below:b.As-Found Setpoint Evaluation: Describe how surveillance test resultsand associated TS limits are used to establish operability of the safety system. Show that this evaluation is consistent with the assumptions and results of the setpoint calculation methodology. Discuss the plant corrective action processes (including plant procedures) for restoring channels to operable status when channels are determined to be "inoperable" or "operable but degraded." If the criteria for determining operability of the instrument being tested are located in a document other than the TS (e.g. plant test procedure) explain how the requirements of 10 CFR 50.36 are met.c.As-Left Setpoint Control: Describe the controls employed to ensure thatthe instrument setpoint is, upon completion of surveillance testing, consistent with the assumptions of the associated analyses. If the controls are located in a document other than the TS (e.g., plant test procedure) explain how the requirements of 10 CFR 50.36 are met.4.For Setpoints That Are Determined Not to Be SL-related: Describe themeasures to be taken to ensure that the associated instrument channel is capable of performing its specified safety functions in accordance with applicable design requirements and associated analyses. Include in your discussion information on the controls you employ to ensure that the as-left trip setting after completion of periodic surveillance is consistent with your setpoint methodology.

Also, discuss the plant corrective action processes (including plant procedures) for restoring channels to operable status when channels are determined to be "inoperable" or "operable but degraded." If the controls are located in a document other than the TS (e.g., plant test procedure), describe how it isensured that the controls will be implemented.

REFERENCES:

1.Letter from Timothy J. Kobetz, NRC, to Technical Specifications Task Force (TSTF),"TSTF Traveler 493, Revision 1, "Clarify Application of Setpoint Methodology for LSSS Functions," dated December 14, 2006, available on the NRC public website in ADAMS Accession No. ML063450324.2.NRC Regulatory Issue Summary 2006-17, "NRC Staff Position on the Requirements of10 CFR 50.36, 'Technical Positions,' Regarding Limiting Safety System Settings During Periodic Testing and Calibration of Instrument Channels," dated August 24, 2006, ADAMS Accession No. ML051810077. 3.Letter from Patrick L. Hiland, NRC, to NEI [Nuclear Energy Institute] Setpoint MethodsTask Force, "Technical Specification for Addressing Issues Related to Setpoint Allowable Values," dated September 7, 2005, ADAMS Accession No. ML052500004.4.Letter from Bruce A. Boger, NRC, to Alexander Marion, NEI, "Instrumentation, Systems,and Automatic Society (ISA) S67.04 Methods for Determining Trip Setpoints and Allowable Values for Safety-Related Instrumentation," dated August 23, 2005, ADAMS Accession No. ML051660447.5.Letter from James A. Lyons, NRC, to Alex Marion, NEI, "Instrumentation, Systems, andAutomation Society S67.04 Methods for Determining Trip Setpoints and Allowable Values for Safety-Related Instrumentation," dated March 31, 2005, ADAMS Accession No. ML050870008.